PIAC responded to the NSW Department of Planning, Industry and Environment’s (the Department) consultation on Tranche 2 regulations for the Electricity Infrastructure Roadmap (the Roadmap). PIAC strongly supports the objectives of the Roadmap and most of the measures set out to achieve them.
We respond to the specific stakeholder questions and provide further detail on our approach to cost and risk sharing for Renewable Energy Zone infrastructure.
PIAC considers the method for determining the derating factor should not be defined in the regulations. Rather, the regulations should contain principles to guide the Energy Security Target Monitor (the Monitor) in creating a method for determining the derating factor.
PIAC is generally supportive of the proposed principles for carrying out competitive tenders, but recommends an explicit principle around the long-term interest of consumers or consideration of cost and risk allocation is included.
The Consumer Trustee should prefer long duration storage over firming infrastructure according to how either resource meets the Infrastructure Investment objectives as well as the additional objectives and principles concerning the long-term interests of consumers, resilience to climate change impacts, and appropriate risk and cost allocation. PIAC considers renewable sources and storage are the most cost effective and reliable means of meeting NSW’s dispatchable capacity and firming requirements.
In line with PIAC’s proposed approach to REZ cost and risk sharing, we consider there is a need for a sub-classification for shared REZ network infrastructure that has a regulated component recovered from consumers and contestable component recovered from generators.
